The defendant is charged [in count
___] with criminally negligent homicide. The statute defining this offense
reads in pertinent part as follows:

a person is guilty of criminally
negligent homicide when, with criminal negligence, (he/she) causes the death of
another person.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - Cause of deathThe first element is that the
defendant caused the death of <insert name of decedent>. This means that
the defendant's conduct was the proximate cause of the decedent's death. You must
find proven beyond a reasonable doubt that <insert name of decedent> died
as a result of the actions of the defendant. <See
Proximate Cause, Instruction 2.6-1.>

Element 2 - Criminal negligenceThe second element is that the
defendant was criminally negligent in causing the death. <See
Criminal Negligence, Instruction 2.3-5.>

ConclusionIn summary, the state must prove
beyond a reasonable doubt that 1) the defendant caused the death of <insert
name of decedent>, and 2) the defendant was criminally negligent when
(he/she) caused the death.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of
criminally negligent homicide, then you shall find the defendant guilty. On the
other hand, if you unanimously find that the state has failed to prove beyond a
reasonable doubt any of the elements, you shall then find the defendant not
guilty.